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United Kingdom Action Plan Review 2021-2023

This product consists of an IRM review of the United Kingdom (UK)’s 2021-2023 action plan. The action plan is made up of five commitments, which the IRM has organised into six.[1] This review emphasises its analysis on the strength of the action plan to contribute to implementation and results. For the commitment-by-commitment data, see Annex 1. For details regarding the methodology and indicators used by the IRM for this Action Plan Review, see section III. Methodology and IRM Indicators.

Overview of the 2021-2023 Action Plan

The UK’s fifth action plan includes a promising commitment on open contracting, while also covering new topics like open justice and algorithmic transparency and accountability. Despite iterative dialogue between stakeholders during the co-creation process, civil society was strongly dissatisfied with the government’s unilateral changes that weakened the ambition of commitments at the last stage of the process. The UK should use the opportunity for amending the action plan to restore a strong domestic OGP process.


Participating since: 2011

Action plan under review: 2021-2023

IRM product: Action Plan Review

Number of commitments: 6

Overview of commitments:

  • Commitments with an open gov lens: 6 (100%)
  • Commitments with substantial potential for results: 1 (17%)
  • Promising commitments: 1 (17%)

Policy areas carried over from previous action plans:

  • Open contracting
  • Health sector transparency
  • Anti-corruption and international illicit finance

Emerging in this action plan:

  • Open justice
  • Algorithmic transparency and accountability

Compliance with OGP minimum requirements for Co-creation:

  • Acted according to OGP process: No

The UK’s fifth action plan builds on previous efforts in open contracting, health sector transparency, and international illicit finance, while also pursuing new areas of open justice and algorithmic transparency and accountability.[2] Commitment 1 on open contracting is a promising commitment which includes activities that could considerably improve the transparency of government procurement. The other commitments, though verifiable, lack specific and measurable milestones that would allow detailed analyses of their potential for results. Some commitments involve engaging stakeholders, but the structures of these engagements and intended results are not well-defined.

The co-creation process kicked off at a stakeholder meeting in December 2020.[3] Government and civil society participants agreed to explore nine themes[4] as potential commitments and working groups were formed around each theme.[5] The point of contact (PoC) at the Cabinet Office invited relevant government representatives to join the working groups, while the UK’s Open Government Network (OGN) oversaw civil society participation and appointed a civil society co-chair for each group. The theme of anti-corruption and international illicit finance (Commitment 5) did not have a working group. Instead, the Cabinet Office drew upon ongoing work from the UK’s chairmanship of the G7. The Home Office had already been discussing these initiatives with civil society through the UK Anti-Corruption Coalition[6] and the Cabinet Office did not want to duplicate these existing discussions.[7]

The level of engagement in the working groups varied by theme, but the PoC noted that engagement was stronger than under the previous action plan.[8] Membership of, and discussions in, the working groups were kept flexible. This approach produced mixed results. For some themes, stakeholders had clear expectations from past commitments that allowed them to quickly reach a consensus on deliverables (i.e., open contracting). For new themes, discussions were less focused due to lack of past experience in OGP processes (i.e., open justice). Some themes were excluded because the working groups could not agree on a set of draft activities that the Cabinet Office considered workable (i.e., natural resources/climate change and standards and public life). The PoC noted that it was challenging in some working groups to achieve a balance between having a diversity of views and the necessary expertise in the topics.[9] Meanwhile, both civil society and the PoC felt that not having the right people at the discussions, either in terms of thematic expertise or decision-making authority, made co-creation more difficult.[10] Nonetheless, both the PoC and the OGN chair acknowledged that their counterpart remained dedicated to the process, despite external constraints (there were several ministerial turnovers at the Cabinet Office during the co-creation period) and limited resources (the OGN chair and other civil society stakeholders had volunteered their time to organise civil society participation[11]).

The draft commitments were sent for ministerial approval in late 2021, before their adoption and submission to OGP. At this stage, many commitments had activities removed or significantly reduced in ambition, without further explanation or consultation with non-government stakeholders. For example, the commitment on international illicit finance saw the removal of a key activity around the Economic Crime Bill, while the commitment on algorithmic transparency and accountability was reduced to “gauging the feasibility” of mapping existing appeal mechanisms. The ministerial approval procedures did not allow for stakeholders to be given feedback around how or why the changes were made before the deadline for action plan submission (31 December 2021).[12] Unlike the previous action plan, the commitments in the fifth plan did not list any civil society partners that would support their implementation, indicating a change in the level of civil society-government co-ownership over the plan. After the publication of the action plan, the OGN put out a statement criticising the last-minute changes and what they saw as a failure of the government to engage civil society on key areas of reform.[13]

As a member of the OGP Steering Committee, the UK should ensure that its domestic OGP process strengthens its status as a global leader in open government. At the same time, recent changes to the domestic and international context could provide greater momentum for strong implementation, particularly around open contracting (in light of the new Procurement Bill), and international illicit finance (in light of Russia’s invasion of Ukraine). Before the end of August, the IRM recommends using the opportunity afforded to OGP members to amend their action plans. The UK government and the OGN could work together to revive the working groups (with targeted civil society participation), to agree on amendments to the existing commitments that were removed or altered and revisit the themes that were not covered in the action plan (such as freedom of information, natural resources/climate change, and standards in public life). It may also be beneficial to formalise the multi-stakeholder forum to bring more stability and consistency to the discussions. Finally, the UK could ensure strong implementation of Commitment 1 on open contracting by putting in place mechanisms to check the accuracy of procurement data and using contracting data to address gender and regional inequalities in government procurement.

Promising Commitments in the UK’s 2021-2023 Action Plan

The following review looks at the commitment that the IRM identified as having the potential to realise the most promising results. This review will inform the IRM’s research approach to assess implementation in the Results Report. The IRM Results Report will build on the early identification of potential results from this review to contrast with the outcomes at the end of the implementation period of the action plan. This review also provides an analysis of challenges, opportunities and recommendations to contribute to the learning and implementation process of this action plan.

The IRM has selected Commitment 1 on open contracting to review in greater detail due to its measurable indicators and potential to significantly improve transparency of government procurement. The other commitments are summarised below but are not reviewed in greater detail as promising commitments, due to lack of specificity of their activities. The IRM recommends amending these commitments by revisiting earlier ideas from the working groups and making the activities more specific and measurable.

Commitment 2 aims to strengthen public access and understanding of the justice system by improving court data, publishing case law, improving access to existing information on hearings and reporting restrictions, and facilitating observation of remote hearings. However, these milestones lack measurable indicators or baselines that would help in assessing the extent to which they will improve existing practices. Moreover, all milestones are “ongoing”, indicating they aim to continue existing policies. The UK could revisit the priorities of the open justice working group that were in a draft of this commitment but later removed.[14] These included providing complete coverage of judgments and decisions from all courts and tribunals on the new database launched by the National Archives. Other activities involved appointing civil society members to the newly created Senior Data Governance Panel through a transparent process and creating a user group to raise issues with access to court information for the panel.[15]

Commitment 3 focuses on transparency and accountability of algorithmic-assisted decisions. While the focus on accountability is commendable (owing to civil society’s original prioritisation), the UK government reduced the scope from mapping existing legal requirements for appeal mechanisms around algorithmic-assisted decisions and sharing this information with the public, to “gauging the feasibility” of mapping.[16] According to the civil society co-chair of the data ethics working group, the government has so far not engaged the OGN on how it intends to carry out the mapping exercise.[17]

During implementation, the mapping exercise could be used to improve compliance by teams building algorithms with existing accountability requirements and to address gaps in existing laws. Where needed, the UK could establish new mechanisms for citizens to appeal algorithmic-assisted decisions and develop guidelines for building algorithms responsibly. In addition, the UK could develop ways for the government to engage affected people as part of algorithmic impact assessments, for example by creating forums for the public to discuss algorithm-assisted decisions with government officials. The UK could also encourage uptake of the public sector with the Algorithmic Transparency Standard[18] and revisit earlier working group discussions around increasing transparency of the procurement of algorithms, possibly in collaboration with the open contracting working group (Commitment 1).[19] Lastly, the UK should leverage its involvement in OGP’s Open Algorithms Network to learn from other countries’ work in this area.[20]

Commitment 4 aims to improve access and transparency of health data and decision-making relating to public health. This commitment has three objectives: 1) transparency and engagement around the use of health data, 2) standards and interoperability of health data, and 3) transparency and monitoring of clinical trials. Because of the divergence of the third objective from the other two, the IRM has looked at these milestones as a separate commitment (4.2) from the other two (4.1).

Under the first objective of Commitment 4.1, the National Health Service and Department of Health and Social Care will work with stakeholders and health users to “co-design a reset of how they can be involved in decisions about how data is used”. The UK could revisit ideas discussed by the working group on health, such as improving transparency and public awareness of how health data is collected and for what purposes, with a focus on health data collected and used during the COVID-19 pandemic.[21] Moreover, the civil society co-chair recommended greater emphasis on diversity, equity and inclusion in the health sector.[22] The second objective involves developing common standards around data interoperability across the health and adult social care sectors, though the civil society co-chair noted that there were few discussions in the working group around this topic.[23] Another civil society expert believed that the activities under this objective are statements of existing government policy.[24]

The third objective (Commitment 4.2) aims to strengthen transparency of clinical trials. The activities involve registering all clinical trials (starting with medicines) and monitoring and publishing metrics on performances of communities against transparency requirements for research. This commitment is in line with an existing strategy from the Health Research Authority (HRA) to make all government-funded trials open by 2023[25] and is the result of long-term engagement with civil society. According to a civil society representative, given the international nature of clinical trials, this commitment offers the UK an opportunity to become a global leader in this area.[26] During implementation, the government could create opportunities for ongoing civil society engagement in monitoring the implementation of research transparency requirements. The government could also explore publishing all research used by chief scientists to inform government decisions around public health.

Commitment 5 aims to improve transparency and collaboration in the UK government’s efforts to address international corruption and illicit finance. The activities derive from the UK’s G7 presidency and involve continuing to engage the Beneficial Ownership Leadership Group, helping Overseas Territories implement publicly accessible registers of company beneficial ownership, and engaging with civil society and the private sector in domestic and multilateral spaces (i.e., the 2021 UNCAC Conference of States Parties and the Summit for Democracy Year of Action). It also entails engaging stakeholders in the development of the successor to the UK’s Anti-Corruption Strategy and a new Economic Crime Plan, as well as strengthening transparency of asset recovery and return.

While some activities represent ongoing work, the commitment includes new activities, particularly publishing annual data on international asset returns and recovered assets stemming from proceeds of crime, and publicising bilateral agreements on the use of returned assets. However, the OGN criticised the government’s removal of plans to introduce a new Economic Crime Bill, which would have included a reform of Companies House, a reform of the limited partnerships law and the introduction of a register of overseas entities owning property in the UK.[27] The UK government could also follow recommendations by Transparency International UK to support Crown Dependencies and Overseas Territories to ensure that they will meet the goal of introducing public registers by 2023. The UK could also require companies that claim they do not know who their beneficial owner is, or do not believe they have one, to outline how the company is controlled, and increase the frequency of companies having to report changes to their beneficial owners.[28] Lastly, the UK government could introduce verification checks on the property register and investigate and remove false information.[29]

Table 1. Promising commitments

Promising Commitments
Commitment 1: Open contracting – This commitment would require all contracting authorities to implement the Open Contracting Data Standard. It will also increase the availability of above-threshold tenders and awards.

[1] In addition to the five commitments, the action plan references potential future work around local transparency, to be led by the Department for Levelling Up, Housing and Communities (added to the action plan by the government without civil society input). As the details of this work will be published in 2022, during the action plan’s implementation period, the IRM has not assessed it as a commitment in this Action Plan Review.

[2] Open Government Partnership, UK Open Government National Action Plan 2021-2023,

[3] UK Open Government, Strategic discussion on open government multistakeholder forum, 9 December 2020,

[4] These themes were: 1) open contracting/procurement, 2) open justice, 3) data ethics (including algorithmic transparency), 4) health, 5) freedom of information, 6) misinformation, 7) the environment (including natural resources and climate change), 8) democracy building, and 9) standards and public life. Some of these topics were discussed by stakeholders on an ad hoc basis but did not have individual working groups. These included freedom of information, misinformation and democracy building.

[5] Readouts for all working group meetings were published on the OGN website,

[6] UK Anti-Corruption Coalition, 

[7] IRM interview with Sam Roberts, point of contact to OGP at the Cabinet Office, 6 May 2022.

[8] IRM interview with Sam Roberts, point of contact to OGP at the Cabinet Office, 6 May 2022.

[9] IRM interview with Sam Roberts, point of contact to OGP at the Cabinet Office, 6 May 2022.

[10] IRM interview with Kevin Keith, Open Government Network, 13 May 2022, and IRM interview with Sam Roberts, point of contact to OGP at the Cabinet Office, 6 May 2022. For example, the civil society co-chair for the working group on health felt that the people that would have enabled deeper discussions around the topic from the Department of Health and Social Care or the National Health Service were not present at the meetings (IRM email correspondence with Mor Rubinstein, civil society co-chair of the health working group, 23 May 2022.).

[11] IRM interview with Kevin Keith, Open Government Network, 13 May 2022.

[12] IRM interview with Sam Roberts, point of contact to OGP at the Cabinet Office, 6 May 2022.

[13] UK Open Government, UK government backslides on commitments to open government in new national action plan, 2 February 2022,

[14] Open Justice NAP5 Draft Commitment,

[15] A Lawyer Writes, Open government at risk, 31 January,

[16] IRM email correspondence with Peter Wells, civil society co-chair of the data ethics (algorithmic transparency) working group, 6 April 2022.

[17] IRM email correspondence with Peter Wells, civil society co-chair of the data ethics (algorithmic transparency) working group, 6 April 2022.

[18], Algorithmic transparency standard, 29 November 2021,

[19] NAP5 Draft Commitment Template,

[20] Open Government Partnership, Open algorithms network,

[21] Health commitments,

[22] IRM email correspondence with Mor Rubinstein, civil society co-chair of the health working group, 23 May 2022. See also

[23] IRM email correspondence with Mor Rubinstein, civil society co-chair of the health working group, 23 May 2022.

[24] Information provided to the IRM by Sam Smith, medConfidential, 8 May 2022.

[25] NHS, Health Research Authority, Research transparency, 11 October 2021,

[26] Information provided to the IRM by Sam Smith, medConfidential, 8 May 2022.

[27] UK Open Government, UK government backslides on commitments to open government in new National Action Plan, 2 February 2022, Parliament later passed the Economic Crime Bill in March 2022 in light of Russia’s invasion of Ukraine, see

[28] Transparency International UK, Economic crime bill: Interim measures essential to prevent asset flight, 9 March 2022,

[29] Transparency International UK, Economic crime bill analysis: Gaps in legislation could limit impact, 1 March 2022,


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